PRIVACY POLICY
WHO ARE WE AND WHAT IS THIS DOCUMENT?
MANOMAYA, which is located 44 rue Cauchy, 94110 Arcueil, France and can be contacted by email at: contact@coachguitar.com, (hereinafter "MANOMAYA"), develop and publish mobile apps and games (hereinafter “MANOMAYA Apps and Games”).
MANOMAYA is very mindful of respecting your private life and the confidentiality of Personal Data relating to you (hereinafter “Personal Data”). This privacy policy is intended to inform you of how your Personal Datas are collected, processed and stored by MANOMAYA and its processors when you use the MANOMAYA Apps and Games and related services, regarding MANOMAYA’s ads and ads services as well as MANOMAYA’s website.
By using and or registering on MANOMAYA Apps and Games and MANOMAYA’s website (i.e. : www.coachguitar.com) you hereby accept and agree to be bound by the present Privacy Policy.
MANOMAYA undertakes to process your Personal Data in accordance with the applicable laws and regulations, and in particular the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, or "GDPR", and Law No. 78-17 of 6 January 1978 on information technology, data files and liberties, in its current version (hereinafter the “Applicable Regulations”).
Please note that MANOMAYA can amend this privacy policy at any time, in full or in part. If the privacy policy is amended, you will be informed by a push notification or an email sent to you with a link toward the updated privacy policy.
MANOMAYA may collect and process your Personal Data to :
1. Develop and publish MANOMAYA Apps and Games,
2. Serve advertising tailored to the your interests and
3. Operate our MANOMAYA’s websites.
1. MANOMAYA APPS AND GAMES
1. WHAT PERSONAL DATA DO WE COLLECT AND WHAT FOR?
MANOMAYA processes your Personal Data for the purposes and on the legal bases set out below.
1. Personal Data collected when you register on the App
What kind of Personal Data: If available, when you register on the App, you must provide a certain amount of information, particularly your username, email and password. You may also add a profile picture and a short presentation to your profile if available.
If available, you can also decide to sign up with Apple, using your Apple ID, or with Facebook which will transmit to MANOMAYA the public information on your Facebook profile: name, surname, profile picture, and if you chose to share it or if authorized in your Facebook settings, your email address or with Google which will transmit to MANOMAYA the public information on your Google profile: name, surname, profile picture, and if you chose to share it or if authorized in your Google settings, your email address. Please note that if you chose to hide your email address, MANOMAYA won’t have it, but we will nevertheless be able to communicate with you through Apple or Facebook or Google.
Legal basis: MANOMAYA processes such Personal Data for the creation and management of your account and for providing the services offered via MANOMAYA Apps and Games. This processing is necessary for entering into and executing a contract with you.
You are informed that MANOMAYA also uses your email address to send you service messages, and information relating to the MANOMAYA Apps and Games (e.g. contents created by the community, tutorials, new features etc.), and direct marketing emails or newsletters relating to other similar products or services offered by MANOMAYA, on the basis of its legitimate interests to communicate with you and inform you of new products or services.
You hereby acknowledge that some of your Personal Data (username and profile picture) will be visible to other users of the MANOMAYA Apps and Games when you post content.
Please note that most of the time, you can also access the MANOMAYA Apps and Games as a "visitor", without registering. The above Personal Data will then not be collected.
2. Personal Data collected when you subscribe
What Kind of Personal Data: In case of in-app purchases, your card details and invoice information (name, surname and postal address) are collected and processed by Google or Apple or Facebook, depending on the app store of your device.
Legal Basis: Such Personal Data will only be processed for the payment or subscription you ordered. This processing is necessary for entering into and executing a contract with you.
3. Personal Data collected when you contact MANOMAYA through MANOMAYA Apps and Games
What Kind of Personal Data: While you are using the MANOMAYA Apps and Games, you may contact MANOMAYA for various purposes. While doing so, MANOMAYA might collect Personal Data such as your e-mail address, your name, surname, and any other information you include in your messages.
Legal Basis: MANOMAYA will process your Personal Data based on its legitimate interests to process and answer your questions and claims.
4. Personal Data collected when you use the MANOMAYA Apps and Games
What kind of Data: While you use MANOMAYA Apps and Games and in order to better organize and manage the contents presented on the MANOMAYA Apps and Games, to run analytics and understand how users interact with our product and services in order to continuously improve it, and to to serve advertising tailored to the preference and interests of our users, MANOMAYA may collect Data limited to:
· The apps you are using
· Your IP address
· Your Mobile Advertising ID (Apple IDFA or Google AAID - which are technical identifiers developed by mobile operating systems for advertising purposes which remain under your control and can be reset or erased at any time in through your device settings)
· Technical information about the device you use and your connection (user agent, type of connection, timestamp)
· Data pertaining to your activities on our applications and notably the way in which you interact with our applications (for instance, how and when you use our applications) and with the advertising served in our applications (for instance, number of ads served, potential clicks)
Legal Basis: Those Personal Data are collected upon your express consent.
2. WITH WHOM MAY YOUR DATA BE SHARED AND WHY ?
The first time you connect on MANOMAYA Apps and Games, a pop up will be displayed, informing you that if you give your consent, your advertising ID (IDFA) and other data, such as location data, and other demographic and interest data about you will be collected and transmitted to our Ad partners and Analytic companies (see-below) for the purpose of providing you with a personalized advertising experience and analytics purpose. You are free to refuse or agree to such processing.
When you consent to the collection of data for advertising and analytics purpose, we may share the data listed above with the following categories of recipients:
Those partners usually collect data via their own tools (software development
kits or “SDK”). you will find a list of our partners implemented advertising
SDK through our applications and the privacy policies of their services that
describe their practices and allow you to exercise your rights directly toward
them hereafter:
· AppsFlyer
https://www.appsflyer.com/services-privacy-policy/
https://www.facebook.com/about/privacy
https://policies.google.com/privacy
· Appodeal
https://appodeal.com/ccpa-privacy-policy/
· Amplitude
https://policies.google.com/privacy
· Intercomm for client support and ticketing;
https://www.intercom.com/legal/privacy
· SendinBlue emailing;
fr.sendinblue.com/legal/privacypolicy/
·
Amazon AWS
https://aws.amazon.com/privacy/?nc1=h_ls
2. PERSONALIZED ADVERTISING
1. WHAT PERSONAL DATA DO WE COLLECT AND WHAT FOR?
MANOMAYA Ads services allow MANOMAYA and its publisher partners (most of the time MANOMAYA Ads partners are third party mobile application providers) to monetize advertising inventory by allowing advertisers to serve personalized advertising to users.
What kind of Data: While you use the Apps and in order to help advertiser promote their products and services and improve our own Ads services, MANOMAYA may collect data limited to:
· the apps you are using
· Your IP address
· Your Mobile Advertising ID (Apple IDFA or Google AAID - which are technical identifiers developed by mobile operating systems for advertising purposes which remain under your control and can be reset or erased at any time in through your device settings)
· Technical information about the device you use and your connection (user agent, type of connection, timestamp)
· Data pertaining to your activities on our applications and notably the way in which you interact with our applications (for instance, how and when you use our applications) and with the advertising served in our applications (for instance, number of ads served, potential clicks).
Legal Basis: In order to deliver such services for its partners, MANOMAYA can receive and process data for different legitimate purposes:
MANOMAYA ads services help advertisers promote their products and services to an audience that has demonstrated interests in similar products and services and allow them to optimize their marketing spends.
MANOMAYA is committed to constantly improve the services delivered to its publishers and advertisers. In order to do so, MANOMAYA Ads processes the data listed above in a way that notably allows it to better understand how users interact with the ads of our advertiser partners and optimize their user experience.
2. WITH WHOM DO WE SHARE YOUR PERSONAL DATA?
Data collected for the purposes of MANOMAYA Ads services are only shared with the following categories of recipients and only to the extent such data is necessary for the purpose they are following:
3. MANOMAYA WEBSITE
1. WHAT PERSONAL DATA DO WE COLLECT AND WHAT FOR?
1.1 When you browse through our website
What kind of Data: Like on most websites, while browsing and using MANOMAYA’s website, MANOMAYA might collect and process certain information about your connection and device(s) for the website to operate properly. MANOMAYA also uses cookies and similar technologies to analyze how the users interact with our services and administer the website as well as to follow conversion rates from ad campaigns. Cookies are small text files stored on your browser that allow the collection of non-personally identifiable information related to your navigation on a website.
You can control the use of cookies in your browser settings or using the cookie management banner, but if you choose to disable cookies it may affect certain websites’ functionalities.
The data that MANOMAYA collect is limited to:
· Browsing events and interactions with the website’s contents and services
· Cookie identifiers, IP address and technical information related to your browser and/or device (user agent).
Legal Basis: MANOMAYA collects such information in order to provide you with the services and to better optimise MANOMAYA’s website and ads campaign based on its legitimate interests.
4. HOW LONG DO WE STORE YOUR PERSONAL DATA FOR?
You are hereby advised that MANOMAYA shall not keep Personal Data collected, received and processed for the purposes described in this policy longer than necessary for the purposes described above in this section.
It means that for Data collected and processed when registering on MANOMAYA Apps and Games, MANOMAYA shall store your Personal Data for any length of time required for the use of your account, as such, your Personal Data will be permanently deleted when you delete your account. If your account remains inactive for a period of 3 years after the final user action, MANOMAYA will send you an email to inform you of the deletion of your account.
You are hereby informed that MANOMAYA reserves the right to store your Personal Data in its temporary archives where strictly necessary to defend its rights in the event of a dispute, for the applicable limitation period.
Also, please note that considering its status of hosting service provider, MANOMAYA is subject to a legal obligation to retain some Personal Data relating to you for a duration of one year, on the basis of article 6.II of the Law 2004-575 of 21 June 2004 on confidence in the digital economy (LCEN).
5. HOW CAN YOU EXERCISE YOUR RIGHTS?
In accordance with the Applicable Regulations, you have the rights to access, rectify, and delete your Personal Data. Under the conditions of the Applicable Regulations, you also benefit from the rights to request the limitation of the processing, the portability of your Personal Data, and the right to object to processing for reasons pertaining to your personal situation when the processing is based on MANOMAYA’s legitimate interest. You can also communicate instructions about the fate of your Personal Data in the event of your death.
You can also, at any time, and without reason, object to the processing of your Personal Data for the purposes of direct marketing.
You can exercise these rights with MANOMAYA by sending your request accompanied by a copy of an identity document by email to the following email address: contact@coachguitar.com or by mail, writing to the following address: MANOMAYA, 44 rue Cauchy, 94110 Arcueil, France.
In any case, you may, at any time, submit a claim to the CNIL (French Data Protection Authority) (www.cnil.fr).